PBTs used in agriculture fertilizers

October 12, 2000

Dear Seattle Times,

I am writing on behalf of our 40,000 members to thank you for breaking and continuing to cover the story about persistant bioaccumulative toxins (PBTs) being used in agricultural fertilizers. The great work by reporters such as Duff Wilson and others at the Times has enabled us as a retailer in the food and agriculture business to be aware of how PBTs have been recycled into our food chain.

Because of your work, we are able to urge the Department of Ecology to strengthen and implement its proposed plan to eliminate dioxin and other dangerous PBTs that are produced, used, stored and disposed of in Washington State.

We support Ecology's recommendation to address the problem of using industrial wastes in agricultural fertilizers. We applaud Ecology for addressing two key points:

"Make steel-mill flue dust subject to the same standards as other hazardous wastes and waste-derived fertilizers applied to land. This waste contains dioxin, arsenic, cadmium, lead and mercury and was widely used in fertilizers in Washington state until the state convinced the Environmental Protection Agency to reverse an exemption that encouraged its use in fertilizers."

"Develop a regulation to limit concentrations of metals (including mercury, lead, cadmium and arsenic) in fertilizers sold within Washington State."

These are good steps in the right direction; however, they do not go far enough. We understand the draft PBT plan as written does not prevent the toxic wastes that contain PBTs from being used for fertilizer. The plan actually would establish amounts of PBT metals (and other metals) that can be added to soil over time and build up. There is no mention of modifying this rule and taking a preventive approach.

We urge Ecology to strengthen the draft plan not just to limit but to prohibit PBT-contaminated substances in any fertilizer product. To allow any amount of PBT-contaminated substances in agriculture does not serve the interest of protecting public health, but rather would protect industrial exploitation of a hidden, hazardous waste disposal method.

Our food supply is contaminated with PBTs including dioxin, mercury, and others not only from fertilizers, but from a myriad of sources including pulp mills, incinerators, and other polluters. Ecology's plan must address all of these sources with concrete actions.

Dioxin from incinerators, for example, goes into the air and the particles settle on grazing land. Cows eat the grass and the dioxin becomes concentrated in their meat and milk. It also concentrates in livestock fed dioxin-tainted grain. Dioxin particles fall into rivers, lakes and the oceans - or get there from runoff. Fish and shellfish ingest particles of sediment and dioxin builds up in their bodies. According to leading epidemiologists, such as Richard Clapp of the Boston University School of Public Health, more than 90 percent of our dioxin exposure comes from food - mostly fish, poultry and non-skim dairy products.

The Department of Ecology's own Web site acknowledges that many PBTs are linked to a variety of adverse effects on human health, including effects on the nervous and reproductive systems and are associated with cancer and developmental problems. The developing fetus and children are most vulnerable because their young systems are still developing.

We applaud Ecology for proposing a plan to identify and explore options for PBT elimination. We understand the need for a timeline, yet we envision a shorter time frame than the target date of 2020 for phasing out use and production of these chemicals. To allow 20 years for cleaner technologies to emerge and replace existing technologies is too lenient and increases the cumulative threat. Setting a shorter timeframe, 2002 or 2003, will prompt substitutes for the products or processes that generate PBTs. Necessity is the mother of invention. We support regulatory requirements, not voluntary compliance.

We urge Ecology to make the draft plan stronger to prohibit these dangerous pollutants from our environment. PBT wastes laden with dioxin and other deadly chemicals have no place in our environment, in fertilizer or our food chain.

Respectfully yours,

Jeff Voltz
Chief Executive Officer

The Department of Ecology is accepting public comments on the PBT draft plan until October 30, [2000]. You may comment to:
Mike Gallagher
Department of Ecology
P. O. Box 47600
Olympia, Washington 98504-7600